G.R. No. 167415 - Gubat vs. National Power Corp.

Atty. Mangontawar M. Gubat claims entitlement to attorney's fees after his clients settled a case with the National Power Corporation (NPC) without his knowledge.
The trial court initially granted Atty. Gubat's claim through summary judgment, but the Court of Appeals reversed this decision, stating that he was enforcing a vacated decision.
Atty. Gubat argues that his entitlement to fees is based on the bad faith of both his clients and NPC, independent of the vacated decision.

In August 1990, three plaintiffs filed civil suits against NPC for damages related to the destruction of their land due to NPC's construction activities.
Atty. Gubat and Atty. Linang Mandangan represented the plaintiffs, with an agreed fee structure.
The cases were consolidated due to similar causes of action, and NPC was declared in default for failing to appear at the initial hearing.

The trial court ruled in favor of the plaintiffs, awarding them damages and attorney's fees.
NPC appealed the decision, during which Atty. Gubat filed a notice of charging lien for his fees.

NPC moved to dismiss its appeal, claiming a settlement had been reached with the plaintiffs, who acknowledged receipt of payment.
Atty. Gubat contended that he was not informed of the settlement and that the plaintiffs conspired with NPC to deprive him of his fees.

After the case was remanded for a new trial, Atty. Gubat filed a motion for partial summary judgment for his attorney's fees, asserting that the compromise agreement was made in bad faith.
The trial court granted his motion, finding that the parties had conspired to deprive him of his fees.

NPC filed a petition for certiorari, arguing that the trial court's decision was based on a vacated ruling and that Atty. Gubat's claim for fees should be against the plaintiffs.
The Court of Appeals ruled that Atty. Gubat's attempt to enforce a vacated decision was erroneous and that the trial court had committed grave abuse of discretion.

Atty. Gubat argued that he was not informed of the settlement and that NPC acted in bad faith.
He maintained that the trial court's summary judgment was proper and that the CA's certiorari petition was an improper mode of appeal.

The Supreme Court found Atty. Gubat's petition lacked merit, stating that he improperly resorted to a petition for certiorari instead of an appeal.
The Court emphasized that genuine issues of fact existed regarding bad faith, which required a full trial rather than summary judgment.

The Court reiterated that summary judgment is only appropriate when there are no genuine issues of material fact.
Atty. Gubat's claims of bad faith and lack of notification of the settlement were contested, making summary judgment inappropriate.